Data Breach Notification Burden Grows With First State Insurance Commissioner Mandate

Available at http://www.pillsburylaw.com/siteFiles/Publications/Privacy_Advisory_FINAL_09-16-2010.pdf

Effective August 18, 2010, any entity licensed by or registered with the Connecticut Department of Insurance must notify the Connecticut Insurance Commissioner within five days of an “information security incident” involving a Connecticut resident’s personal health, financial or personal information that places such resident at risk. Connecticut’s insurance notification mandate is the first such measure by a state, adding to the already tangled web of state and Federal data breach notification standards and requirements.

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About John Nicholson

I'm a transactional attorney who focuses on structuring and negotiating large outsourcing transactions (both on and offshore). As part of my work, I've specialized in: - Structuring and negotiating large outsourcing transactions (both on and offshore) including IT outsourcing and various BPOs (including HRO, Facilities Management, Procurement, Finance and Accounting), large systems development and implementations; - Assisting with development of RFPs, proposal evaluation, down select, and negotiation; - US and European privacy laws, including US Safe Harbor, and state privacy and data breach notification laws; and - Privacy, security, legal and contractual issues associated with cloud computing. I'm a frequent speaker on outsourcing, privacy and security issues. Before becoming a lawyer, I was the acting IT director for a mid-size company prior to hiring the CIO and project manager for the company's Oracle Financials implementation.
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